Colorado Csepp Community Recovery Plan
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COLORADO CSEPP COMMUNITY RECOVERY PLAN June 2016 1 Executive Summary Purpose The purpose of the Chemical Stockpile Emergency Preparedness Program (CSEPP) Recovery Plan is to outline the coordination and support activities that occur in the recovery phase following a chemical event at Pueblo Chemical Depot (PCD). The term “recovery” includes measures to assess the hazard and perform other urgent tasks in the area affected by the emergency; a controlled process for reentry, restoration, and remediation; and provision of services to persons, businesses and other organizations affected by the emergency. The primary purpose of recovery activities is to protect public health and safety while returning the community to normal or near normal conditions. The Colorado CSEPP Team has been an active participant in the evolution of CSEPP recovery planning and preparedness, beginning April 15, 1992 when it identified the programmatic need for resolution of recovery issues during a Table Top Exercise (TTX) conducted in Pueblo. Between January 2014 and August 2015, a series of seminars and tabletop exercises had been conducted focusing on different aspects of the plan with the goal of validating its contents. Additional stakeholders were brought into the processes that were not included when the original plan was written. Changes in regulatory requirements were also updated. This was accomplished as the first set of chemical munitions was being destroyed. Management of such an incident will conform to the principles of the National Incident Management System (NIMS) as required by Colorado Executive Order D 011 04, dated December 6, 2004 and the PCD and / or PCAPP Contingency Plan pursuant to the facility permit or interim status plans and the Colorado Hazardous Waste Regulations, 6 CCR 1007-3, Section 264.1(g)(8)(iii). Context of Recovery from a Chemical Event It is impossible to predict the exact situation that would follow in the aftermath of a chemical event. Much would depend on the origin of the event, the severity of the event, the response to it, and other parameters such as the weather. However, at least some circumstances may be anticipated in advance, and this Plan is based on those assumptions to a considerable extent. Planning for recovery should take into account the probable circumstances and should incorporate measures to address the issues they will raise. It should be noted that a chemical event may or may not involve a release of chemical agent, and when there is a release; it may or may not be enough to be detectable or pose a hazard off-post. A recovery process should be considered for any chemical event in which the public is notified of an emergency and protective action recommendations are issued to the public. However, the recovery process will be simpler if, after the situation is assessed, it is determined that there was no release or a minimal release. The Plan is not based on any assumption as to the severity of 2 the event; it is intended to cover the full range of chemical events ranging from purely precautionary notices to severe events involving significant hazards off-post. Assumptions For severe events where there is a significant release of chemical agent and a possibility that it was transported off-post, it can be anticipated that there will be uncertainty as to the nature and extent of any residual hazard. Protective actions will likely have been initiated based on assumptions as to the amount of agent released (e.g., the maximum credible event or MCE), combined with computer modeling of its dispersal. The process of determining whether there is any residual hazard may likely take a few days to a few weeks. If investigation at the scene of the event reveals no releases, that period might be reduced. If investigation or monitoring indicates a possibility of aerosol deposition, that period might be increased. In such an event, off-post officials would have a number of concerns relating to monitoring, sampling, hazard assessment, and protective actions during the recovery period, specifically including: • Concern for aerosol deposition. Under some circumstances, it is possible that chemical agent would be dispersed as an aerosol (very small droplets) and subsequently deposited as contamination on downwind surfaces off-post. Studies have shown that this is unlikely to occur, and if did occur it would be limited to a small area near the installation. An unusual combination of factors is needed to make aerosol deposition a possible health risk beyond the installation boundary: detonation of a number of explosively configured munitions filled with persistent agent (mustard), combined with a fire hot enough to cause the munitions to detonate and carry the aerosols well above ground level in a heated plume. In addition, the right atmospheric conditions are needed to transport the aerosol significant distances in order for the droplets to fall out beyond the installation boundary. • Concern for other hazards caused by the chemical event. The chemical event may cause secondary hazards in the affected area. For example, rapid evacuation of the population might leave some industrial facilities or critical infrastructures vulnerable to loss or damage that, in turn, could pose a health and safety threat. Traffic accidents on evacuation routes in the hazard area might create situations that necessitate response in potentially hazardous areas to save lives. • Concern for other hazards not caused by the chemical event. Disasters such as earthquakes or tornadoes might cause or contribute to a chemical event, create separate response requirements, and complicate the chemical event response. • Concern for those who evacuated from areas that were never at risk. Because of the conservative assumptions that are built in to the protective action decision-making process, it is likely that many people will have evacuated from areas that were never dangerous. This population will strain resources to provide care and shelter for evacuees until they return home. 3 COLORADO CSEPP COMMUNITY RECOVERY PLAN DISCLAIMER: The Colorado Department of Public Health and Environment (CDPHE) recognizes that various aspects of sampling, collection, and clean-up from a chemical agent incident at the Pueblo Chemical Depot remain fluid. Thus, as a regulatory agency for hazardous materials within the State of Colorado proposed procedures and criteria are pending review by the Department. Therefore, the Department is unable to fully support this plan in toto. Approval by Designated Authorities This off-post recovery plan is hereby approved as the basis of integrated community chemical event recovery operations for Pueblo County, Pueblo Chemical Depot, and the State of Colorado. Commander, Date Pueblo Chemical Depot Governor of Colorado Date or Authorized Representative 4 Record of Changes Pages Updated By: Date Pages / Subject Revised (Name) 7/1/2012 Name change. Division of Emergency Management Throughout document from the Department of Department of Local Affairs was renamed Office of Emergency Management (moved into the Division of Homeland Security and Emergency Management) within the Department of Public Safety 10/1/12 Removal of references to Service Response Force p. 15, 81, 107, and 118 (deleted from Army Regulation) 1/2/14 Update of publication dates of various documents Throughout document 1/24/14 Inclusion of the Colorado Department of Agriculture p. 14 9/20/15 Removal of reference DA Pam 50-6 Throughout document Distribution City and County of Pueblo Health Department Colorado Department of Agriculture Colorado Department of Public Health and Environment / Hazardous and Waste Management Division Colorado Department of Public Health and Environment / Office of Emergency Preparedness and Response Colorado Department of Public Safety / Division of Homeland Security and Emergency Management EPA Region VIII FEMA Region VIII Pueblo County Sheriff’s Office / Emergency Services Bureau U.S. Army / Assembled Chemical Weapons Alternatives U.S. Army / Chemical Materials Activity U.S. Army / Pueblo Chemical Depot 5 Table of Contents Base Plan…………………………………………………………………………...………………….1 Purpose………………………………….……………………………………….………..……….1 Scope………………………………………………………………………………………………1 Situation Overview…………………………………………………………….……….……….2 Hazard Analysis…………………………………………………………….……….………2 Capability Assessment………………………………………………………..……………..11 Mitigation Overview……………………………………………………………..………….11 Planning Assumptions………………………………………………….………….……………12 Concept of Operations………………………………………………………..………….…………12 Organization and Assignment of Responsibilities…………………………….………..………13 Direction, Control, and Coordination………………………………………………….………23 Information Collection, Analysis, and Dissemination……………………….…………..…….24 Communications……………………………………………………………….………..………25 Administration, Finance, and Logistics………………………………………..…………….………26 Plan Development and Maintenance………………………………………………..……………26 Authorities and References……………………………………………………..……….…………26 ANNEXES Annex A Analytical Laboratories……………………………….…………..……..…….…………28 Annex B Chemical Agent Exposure Standards……………………………..………..….…………30 Annex C Cleanup Procedures under RCRA……………………………..…..……….…………35 Annex D Sampling Interagency Agreement for Environmental Cleanup………..……….………37 Annex E Public Information…………………………………………………..……….…………52 Annex F Sampling Methodology……………………………………………..……….…………59 Annex G Technical Contacts…………………………………………………..……….…………78 Annex H Acronyms……………………………………………………………..……….…………79 Annex I Glossary……………………………………..……………………..……….………….87